An additional reporting obligation will be introduced by the VAT package for businesses that make intra-EU supplies or purchases of services and will create a significant additional compliance burden. The EC lists will be obligatory not only for sales and purchases of goods but also for services supplied to or purchased from entities registered for VAT purposes in other EU Member States.
The EC lists will have to be submitted in accordance with the taxpayer's tax return filing period and the cumulative value of certain transactions. This means that if a taxpayer files monthly VAT returns, or the cumulative value of its EC sales of goods exceeds EUR 100,000 per quarter, EC lists will have to be filed monthly, by the 20th of the following month. If the taxpayer files quarterly returns and the cumulative value of its EC sales of goods does not exceed EUR 100,000 per quarter, EC lists will have to be filed quarterly by the 20th of the month following the quarter in question.
Please note that, from 1 January 2010, the EC lists will have to be submitted to the Tax Authority electronically, which will place an additional administrative burden on companies that previously were not required to file tax returns electronically.
In view of these forthcoming changes, PwC suggests clients to take measures in order to ensure compliance with the new reporting rules, which will come into effect on 1 January 2010.